April 2015 – The American Home Furnishings Alliance has been actively involved in the regulatory development of formaldehyde emission standards – as well as the enforcement framework for those standards – for the last 10 years, beginning with the California Air Resources Board (CARB) and continuing with the U.S. Environmental Protection Agency (EPA).
In early 2006, CARB initiated a process for regulating formaldehyde emissions from composite wood products, including hardwood plywood, particleboard and medium density fiberboard (MDF). The enforcement framework made composite wood panel producers responsible for testing, certification and record-keeping. Furniture manufacturers who produce finished products by laminating composite wood panels and assembling them into a finished furniture product are considered “fabricators” in the CARB enforcement framework.
The CARB regulation was finalized in 2008, with further reduction in the emissions limits completed in 2012. From the outset, AHFA and its members worked closely with regulators as they crafted what would become a “de facto” global standard for composite wood. Throughout the rulemaking process, AHFA member companies worked diligently to implement the CARB requirements for fabricators and consistently called for strong oversight in the regulation to ensure a certified and compliant composite wood supply chain.
In 2010, Congress passed the Formaldehyde Standards for Composite Wood Products Act, or Title VI of the Toxic Substances Control Act (TSCA). Like the CARB rule, this federal legislation established emission standards for formaldehyde from composite wood products. The Act also directed the EPA to propose rules to enforce the act’s provisions. In June 2013, the EPA proposed two rules designed to ensure that composite wood products – whether manufactured domestically or imported – meet the emission standard.
Unlike the CARB enforcement framework, however, the EPA proposed shifting the point of compliance from the composite wood product producer to the furniture manufacturer, who becomes responsible for in-house quality control batch testing and quarterly, third-party, product-type certification.
Although AHFA supports a federal formaldehyde emission standard, it believes the EPA’s proposed enforcement framework ignores definitive research supporting an exemption of laminated products from the definition of hardwood plywood. Research conducted by world-class air quality laboratories demonstrates that finished products have a reduced emission profile from that of a composite panel. Therefore, it is AHFA’s position that there is no public health benefit gained from further testing or regulation once regulated board is finished (laminated) and assembled into final product.
AHFA continues meeting with EPA officials as they move toward publishing a final rule – now anticipated around the end of 2015. AHFA also is now working with the U.S. Consumer Product Safety Commission as it begins to evaluate the consumer health and safety aspects of formaldehyde in consumer products.
- AHFA Responds to NYT Formaldehyde Article